01 Who we are
Simply Will is a trading name of DRGNFLY Studios Ltd, a company registered in England & Wales (company number 17398836), with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, DRGNFLY Studios Ltd is the data controller of the personal data described in this policy. This means we are responsible for deciding how and why your data is used.
We are registered with the Information Commissioner's Office (ICO) under registration number ZC248719. You can contact us about anything in this policy at privacy@simplywill.co.uk.
02 At a glance
- We collect only what we need to help you create, store, and update your will.
- Your will content and vault documents are stored in UK data centres and encrypted with AES‑256.
- We never sell your data and never share it with advertisers.
- You can access, correct, export, or delete your data at any time.
- We only send marketing emails if you have asked us to, and you can opt out anytime.
03 The data we collect
We collect the following categories of personal data:
Account & identity data
Your name, email address, and the encrypted credentials used to sign in. If you enable it, we also store a setting indicating that biometric (Face ID / fingerprint) unlock is active on your device — the biometric data itself never leaves your device and is never sent to us.
Will & estate content
The information you enter to build your will, which may include details of your beneficiaries, executors, guardians, assets and property, gifts and legacies, funeral and personal wishes, and instructions regarding digital accounts. Some of this information may relate to other people (for example, a named beneficiary or executor).
Vault documents
Files you generate or upload to your digital vault, such as your signed will, and the version history of documents you create.
Payment data
Records of the plan(s) you have purchased and the transaction identifiers needed to confirm and support those purchases. Purchases are made through the Apple App Store; we do not receive or store your full card or bank details — these are handled by Apple.
Technical & usage data
Limited technical information such as device type, operating system version, app version, and basic diagnostic or crash information, used to keep the app secure and working correctly.
Communications
Messages you send us (for example, support requests) and, if you joined our waitlist or opted in, your email address for launch and product updates.
04 Sensitive (special category) data
A will can reveal information that UK GDPR treats as "special category" data — for example, funeral wishes may imply religious beliefs, or family arrangements may imply information about health or relationships.
Where you choose to include such information, we process it only because you have given your explicit consent by voluntarily entering it to create the document you have asked us to produce (Article 9(2)(a) UK GDPR). You are never required to provide sensitive information, and you can remove it at any time. We do not use this information for any purpose other than producing and storing your will.
05 How and why we use your data
We only use your personal data where the law allows us to. The table below sets out what we do and our lawful basis for doing it.
| What we do | Lawful basis (UK GDPR) |
|---|---|
| Create and manage your account | Performance of our contract with you — Art 6(1)(b) |
| Generate, store and let you update your will & vault | Contract — Art 6(1)(b); explicit consent for any special category content — Art 9(2)(a) |
| Process your purchase and confirm entitlements | Contract — Art 6(1)(b); legal obligation for financial records — Art 6(1)(c) |
| Provide customer support | Contract — Art 6(1)(b); our legitimate interests in helping you — Art 6(1)(f) |
| Keep the service secure and prevent fraud or misuse | Legitimate interests — Art 6(1)(f) |
| Diagnose faults and improve the app | Legitimate interests — Art 6(1)(f) |
| Send you service messages (e.g. security, account, receipts) | Contract — Art 6(1)(b) |
| Send you marketing or waitlist emails | Your consent — Art 6(1)(a) (withdraw anytime) |
| Comply with legal, tax and regulatory obligations | Legal obligation — Art 6(1)(c) |
Where we rely on legitimate interests, we have balanced those interests against your rights and only proceed where yours are not overridden. You can object to this processing — see Your rights.
06 Children
Simply Will is intended only for adults aged 18 or over who are making a will. Our service is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with data, please contact us and we will delete it.
08 International transfers
Your will content and vault documents are stored in UK data centres (Supabase, West Europe / London region). Some of the service providers listed above process limited personal data outside the UK: RevenueCat (purchase and entitlement records, processed in the United States) and Loops (waitlist and product emails, processed in the United States). Apple's App Store handles payment processing globally as part of providing the App Store service. Fathom Analytics processes only aggregated, anonymous website usage data — never personal data — so no international transfer of personal data arises from its use, regardless of where its infrastructure is hosted.
Where any personal data is transferred outside the UK, we ensure it is protected by an appropriate safeguard recognised under UK data protection law — such as a UK adequacy decision, the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses.
09 How long we keep your data
We keep your personal data only for as long as necessary:
- Account, will and vault data — for as long as your account is open. If you delete your account, we delete this data, subject to the limited exceptions below.
- Payment and transaction records — retained for up to 6 years to meet tax and accounting obligations.
- Support communications — kept for up to 24 months after your query is resolved.
- Waitlist / marketing email — until you unsubscribe or ask us to remove it.
- Backups — deleted data may persist in secure backups for a short period before being overwritten, up to 30 days.
10 How we protect your data
We take the security of your data seriously and apply measures appropriate to how sensitive it is:
- AES‑256 encryption — the encryption standard used by banks and governments — protects documents in your vault.
- Data is encrypted in transit and at rest.
- Optional biometric app lock (Face ID / fingerprint) keeps the app accessible only to you on your device.
- Redundant, secure backups guard against data loss.
- Access to systems is restricted, logged, and limited to what is strictly necessary.
No online service can be guaranteed to be completely secure, but we work hard to protect your data and to keep our safeguards under review. If a data breach ever occurs that is likely to put your rights at risk, we will notify the ICO and, where required, you, without undue delay.
11 Executor & shared access
Simply Will lets you notify a named executor and share access to your vault with them. If you choose to do this, you are authorising us to make the relevant documents available to your executor via a secure, tokenised link that you initiate from within the app. You are responsible for choosing who to notify, and we recommend only sharing access with people you trust.
A separate feature that gates executor access behind a manually reviewed death certificate is planned for a future release and is not part of the current service. We'll update this policy before that feature becomes available.
12 Your rights
Under UK data protection law you have the right to:
- Be informed about how your data is used (this policy).
- Access a copy of the personal data we hold about you.
- Rectify data that is inaccurate or incomplete.
- Erase your data ("right to be forgotten"), in certain circumstances.
- Restrict how we use your data in certain circumstances.
- Data portability — receive your data in a portable format.
- Object to processing based on our legitimate interests, and to direct marketing at any time.
- Withdraw consent at any time where we rely on it.
To exercise any right, email privacy@simplywill.co.uk. We will respond within one month. Exercising your rights is free, and much of your data can also be viewed, edited, exported, or deleted directly within the app.
14 Changes to this policy
We may update this policy from time to time to reflect changes to our service or the law. When we do, we will update the "Last updated" date above, and — for significant changes — notify you in the app or by email. Please review it periodically.
15 Contact & complaints
Get in touch
For any question about this policy or your data, contact privacy@simplywill.co.uk.
Right to complain
We hope to resolve any concern directly. You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk or on 0303 123 1113. We would appreciate the chance to address your concern before you approach the ICO.